In response to EPA’s request for comments on the Emergency Exemption application for sulfoxaflor by the Tennessee Department of Agriculture, the Arkansas State Plant Board, and the Mississippi Department of Agriculture, the National Cotton Council (NCC) strongly urges EPA to grant the requests.

The NCC is the central organization of the United States cotton industry. Its members include producers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehousers and textile manufacturers. A majority of the industry is concentrated in 17 cotton-producing states stretching from Virginia to California. The NCC represents producers who cultivate between 10 and 14 million acres of cotton. Annual cotton production, averaging approximately 16 to 20 million 480-lb bales, is valued at more than $5 billion at the farm gate. The downstream manufacturers of cotton apparel and home furnishings are located in virtually every state. Farms and businesses directly involved in the production, distribution and processing of cotton employ more than 230,000 workers and produce direct business revenue of more than $27 billion. Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 420,000 workers with economic activity well in excess of $120 billion. In addition to the cotton fiber, cottonseed products are used for livestock feed, and cottonseed oil is used as an ingredient in food products as well as being a premium cooking oil.

In recent years, Lygus has become a key pest of U.S. cotton. The Cotton Insect Losses data shows that Lygus was the second most damaging insect pest to cotton in 2015. The tarnished plant bug (Lygus lineolaris, TPB) has become the primary insect pest of cotton in the Mid-South region of the Cotton Belt. It is not uncommon for TPB to cause near-total crop loss in the absence of effective control strategies in areas of the Delta.
Compounding that problem, TPB has become resistant to several classes of insecticides, including the pyrethroids and organophosphates. In order to manage this season long pest, producers must have multiple modes of action (MOA) available. By limiting the MOA, selection for resistant genotypes is increased and application intervals are shortened, resulting in more insecticide use and higher production costs. U.S. cotton producers cannot sustain TPB applications on four to five day schedules throughout the season with limited products and use rates from which to choose. In addition, producers cannot maintain the resistance management strategies recommended by state and federal entomologists without access to active ingredients in other classes of chemistry. Sulfoxaflor has demonstrated effective control of Lygus in field trials.

These three states have sufficiently met the qualification for an Emergency Exemption. Time is critical in order to provide a viable option for yield protection. The NCC is concerned EPA’s decision to open a 15 day comment period ignores the importance and timely response needed to address Emergency Exemptions for Agriculture. The criteria for Emergency Exemption are clearly met in these requests, and additional delays place production at risk. For these reasons, the NCC is urging a timely approval of these Emergency Exemption requests.

The NCC appreciates this opportunity to provide comments in support of approving the Emergency Exemption requests of Tennessee Department of Agriculture, Arkansas State Plant Board, and the Mississippi Department of Agriculture. Additionally, the NCC urges the approval of any similar Emergency Exemption request in a timely manner that will not delay access to necessary crop protection products.